CLA-2-84:OT:RR:NC:N1:102
Marcus Zinn
Hanwha Qcells Georgia, Inc.
100 Qcells Parkway, Suite 250
White, GA 30184
RE: The tariff classification and country of origin of a harmonic planetary reducer
Dear Mr. Zinn:
In your letter dated April 24, 2026, you requested a tariff classification and country of origin ruling to apply
current trade remedies and for marking purposes.
The product at issue is a Harmonic Planetary Reducer, model number HPG-20A-21-F0GCK. The planetary
reducer is configured as a planetary gearbox that reduces rotational speed in a fixed ratio (21:1). The gearbox
consists of an aluminum housing that incorporates six gears and is designed to transmit power to joint
actuators used in various industries such as in robotics, semiconductor manufacturing and machine tools.
The applicable subheading for the planetary reducer will be 8483.40.5010, Harmonized Tariff Schedule of
the United States (HTSUS), which provides for Transmission shafts (including camshafts and crankshafts)
and cranks; bearing housings, housed bearings and plain shaft bearings; gears and gearing; ball or roller
screws; gear boxes and other speed changers, including torque converters; flywheels and pulleys, including
pulley blocks; clutches and shaft couplings (including universal joints); parts thereof: Gears and gearing,
other than toothed wheels, chain sprockets and other transmission elements entered separately; ball or roller
screws; gear boxes and other speed changers, including torque converters: Gear boxes and other speed
changers: Fixed ratio speed changers, multiple and variable ratio speed changers each ratio of which is
selected by manual manipulation: Other: Fixed ratio speed changers. The general rate of duty will be 2.5
percent ad valorem.
With respect to origin, the final assembly occurs in South Korea using components sourced from Japan and
South Korea. The process begins by inserting an input coupling into a housing from South Korea.
Afterwards, six gears from Japan are pressed into the housing and bearings from South Korea are interfaced
fitted as needed. Lastly, the components are bolted in place, and the finished planetary reducer is labeled and
packaged ready for shipment.
When determining the country of origin for purposes of applying current trade remedies under Section 301
and additional duties, the substantial transformation analysis is applicable. See, e.g., Headquarters Ruling
Letter H301619, dated November 6, 2018. The test for determining whether a substantial transformation will
occur is whether an article emerges from a process with a new name, character, or use different from that
possessed by the article prior to processing. See Texas Instruments Inc. v. United States, 681 F.2d 778
(C.C.P.A. 1982). This determination is based on the totality of the evidence. See National Hand Tool Corp. v.
United States, 16 C.I.T. 308 (1992), aff’d, 989 F.2d 1201 (Fed. Cir. 1993).
Here, the final assembly of the planetary reducer involves the insertion and press-fitting of components into a
housing, followed by a bolting process. These processes are not particularly complex and do not substantially
transform the non-South Korean components, such as the six gears. While the South Korean housing encloses
the components, the gears are directly responsible for the transmission of power and constitute a significant
portion of the planetary reducer’s overall bulk and value. Consequently, based on the bulk, value and
significant function of the gears, which are of Japanese origin, the country of origin of the planetary reducer
is Japan.
The holding set forth above applies only to the specific factual situation and merchandise description as
identified in the ruling request. This position is clearly set forth in Title 19, Code of Federal Regulations
(CFR), Section 177.9(b)(1). This section states that a ruling letter is issued on the assumption that all of the
information furnished in the ruling letter, whether directly, by reference, or by implication, is accurate and
complete in every material respect. In the event that the facts are modified in any way, or if the goods do not
conform to these facts at time of importation, you should bring this to the attention of U.S. Customs and
Border Protection (CBP) and submit a request for a new ruling in accordance with 19 CFR 177.2.
Additionally, we note that the material facts described in the foregoing ruling may be subject to periodic
verification by CBP.
The duties cited above are current as of this ruling’s issuance. Duty rates are provided for your convenience
and are subject to change. The text of the most recent HTSUS and the accompanying duty rates are provided
at https://hts.usitc.gov/.
This ruling does not address the applicability of any additional duties, taxes, fees, exactions and/or other
charges, which may apply to the goods discussed herein. This includes, but is not limited to, tariffs and other
duties as provided for in Subchapter III to Chapter 99, HTSUS. Thus, for example, in addition to the
classification stated above, the merchandise covered by this ruling may also need to be reported with either
the Chapter 99 provision under which an additional tariff applies or one of the Chapter 99 provisions
covering exceptions to such tariffs.
This ruling is being issued under the provisions of Part 177 of the Customs and Border Protection
Regulations (19 C.F.R. 177).
A copy of the ruling or the control number indicated above should be provided with the entry documents
filed at the time this merchandise is imported. If you have any questions regarding the ruling, please contact
National Import Specialist Sandra Martinez at [email protected].
Sincerely,
(for)
James P. Forkan
Director
National Commodity Specialist Division